CRA applies the connected corporation tests on the basis of numbers of voting shares

CRA has confirmed that for purposes of the connected corporation tests, having 10% or 50% of the "issued share capital" of a corporation with full voting rights means owning voting shares whose relative number exceeds the percentage threshold – so that (leaving GAAR aside) a CCPC would be "controlled" by a Holdco if for example the Holdco held 100 shares of CCPC with 1 vote per share and an arm’s length shareholder held one share bearing 1000 votes.

Neal Armstrong. Summary of October 2014 APFF Roundtable, Q. 18, 2014-0538081C6 F under s. 186(2).